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Posts tagged ‘OSHA’

10 Things Chemical Plant Operators Need to Know About OSHA’s New Chem NEP


On Nov. 30, OSHA announced the launch of its PSM National Emphasis Program for chemical facilities (Chem NEP). The new Chem NEP expands nationwide a previous 2009 Pilot Chemical Facilities Process Safety Management NEP, which had covered only a few OSHA regions, and established policies and procedures for inspecting workplaces covered by the PSM Standard.

The inspection process under the new Chem NEP includes detailed questions designed to gather facts related to PSM requirements and verification that employers’ written PSM programs are adequately implemented in the field. The intent of the NEP is to conduct focused inspections at facilities randomly selected from a list of worksites likely to have covered processes. The director of OSHA, Dr. David Michaels, announced at the launch of this new NEP that during “the pilot Chemical NEP, [OSHA Compliance] found many of the same safety-related problems that were uncovered during our NEP for the refinery industry … As a result, [OSHA is] expanding the enforcement program to a national level to increase awareness of these dangers so that employers will more effectively prevent the release of highly hazardous chemicals.”
Below are the 10 most important things chemical plant operators need to know about the new nationwide Chem NEP:

 

1. It is effective immediately and has no expiration.
Programmed inspections will begin immediately in all regions. Unlike the Refinery PSM NEP and the Pilot Chem NEP, this directive does not include an expiration date.

 

2. It expands the Chem NEP nationwide.
Whereas the pilot NEP involved only a few select regions under federal OSHA’s jurisdiction, the new nationwide Chem NEP applies to all OSHA regions. And unlike the pilot chem and refinery NEPs, states are required to participate in this emphasis program. If the approved state OSHA plan already has some version of a Chem NEP or wants to implement its own version (within 60 days), the state plan must demonstrate to federal OSHA that its program is at least as effective. Otherwise, the states must adopt this directive.

3. Targets for Chem NEP inspections include:
The types of workplaces inspected under the new Chem NEP are similar to the pilot. OSHA will assemble a master list for each region based on employers who: (1) submitted Program 3 Risk Management Plans to EPA; (2) have a NAICS code for Explosives Manufacturing; (3) appear in OSHA’s enforcement database as having been cited in the past for PSM-related issues; and (4) are known to the area office as operating a PSM-covered process. Any workplaces selected for inspection under OSHA’s Site-Specific Targeting Plan, which also happen to operate a PSM-covered process, will be inspected under the Chem NEP directive. Likewise, inspections arising from an employee complaint, referral or incident involving a PSM issue also will be conducted under the Chem NEP directive. Complaints, referrals and incidents unrelated to PSM may still result in an inspection under this directive at the area director’s discretion.

 

VPP- or SHARP-approved facilities are partially exempt. (They are exempt from programmed inspections, but may be subject to inspection under the Chem NEP upon an employee complaint, incident or referral related to PSM.)

4. The selection of unit(s) includes:
OSHA will attempt to identify “the most hazardous process” as the selected unit(s) for inspection under the Chem NEP. The selection of the unit(s) will be based on the following:
· Quantity of chemicals in the process;
· Age of the process unit;
· Number of workers and/or contractors present;
· Incident and near-miss reports and other history;
· Input from the union or operators;
· Ongoing maintenance activities; and
· 119(o) Compliance Audit findings.

5. Inspection scheduling expectations include:
Every OSHA area office across the country is expected to complete 3-5 programmed Chem NEP inspections per year. The sites selected for inspections will consist of approximately 25 percent workplaces that use ammonia refrigeration and 75 percent all other workplaces with a PSM coverage process.

6. It emphasizes implementation over documentation.
Like the pilot NEP, compliance officers will be focused on implementation of PSM elements in the field rather than relying solely on the quality of the written PSM program.

 

7. It features dynamic list questions.
Like the pilot NEP, the dynamic list-based evaluation under the Chem NEP is a mandatory gap analysis formatted in a series of questions to facilitate evaluation of compliance with various elements of the PSM standard. The list of questions rotates periodically and will not be publicly disclosed. The questions are accompanied by guidance for CSHOs as to what documents to request, interview topics and questions to cover, and potential citations to issue. Each dynamic list includes 10-15 primary and 5 secondary questions. Questions are designed to elicit a “Yes,” “No” or “N/A” determination of PSM compliance, and any “No” will normally result in a citation.

8. The following documents and presentations will be requested:
During a Chem NEP inspection, employers will be asked to produce the following documents:
· List of PSM-covered processes;
· List of units and maximum intended inventories;
· Three years of OSHA 300 logs for employer and contractors, and contract employee injury logs;
· Summary description of PSM program;
· PFDs, P&IDs, Plot Plans and electrical classification drawings for the selected unit(s);
· Description of process and safety systems, safe upper and lower operating limits and design codes and standards for the selected unit(s);
· The initial PHA and the most recent Redo or Revalidation for the selected unit(s) (including PHA reports and worksheets, recommendations and action items and schedule for addressing and completing recommendations and action items); and
· PSM incident reports for the selected unit(s).

 

Before a walkaround inspection, OSHA will request the following presentations:
· Overview of the company’s PSM Program and how it is implemented;
· Identify personnel responsible for implementing each PSM element;
· Description of records used to verify compliance; and
· Process description for the selected unit(s).

 

9. A single issue will yield multiple citation items.
As we reported about the refinery NEP, OSHA was turning a single issue into multiple violations. The agency has memorialized this practice in the Chem NEP directive. The directive advises CSHOs that a single valve change, for example, could implement 11 different PSM elements, and each should be considered for individual citation items.

 

10. Abatement verification and documentation is now mandatory.
Under the pilot NEP, some citations required employers to simply certify that abatement had been completed. Under the new Chem NEP, however, abatement verification and documentation is now mandatory. The NEP also directs CSHOs to review past PSM-related citations issued to the same employer going back 6 years, and identify potential failures to abate and possibly repeat and willful violations.

http://ehstoday.com/standards/osha/OSHA-Chem-NEP-1208/

Report: Congress, Presidents, U.S. Supreme Court Have Obstructed OSHA Regulatory Process


Some OSHA regulations have been delayed for as long as 31 years, with presidents, Congress and the U.S. Supreme Court all contributing to the slowdown in the rulemaking process.

“The requirements on OSHA have nearly paralyzed the agency,” said Justin Feldman, worker health and safety advocate with Public Citizen and author of the report. “As a result, OSHA cannot adequately protect workers from toxic chemicals, heat stress, repetitive use injuries, workplace violence and many other occupational dangers. Inadequate regulation imposes tremendous costs on workers, who may be forced to pay with their health or even their lives.”

Because so much time and resources are spent trying to promulgate fewer standards, Public Citizen asserts that OSHA has been unable to address many other risks. For example, NIOSH has identified 682 toxic chemicals to which workers are exposed. OSHA has no existing regulation for 244 of these chemicals, meaning workers can be exposed to them at any level. For another 196 chemicals, OSHA’s standards offer less protection than NIOSH recommends. OSHA has regulated only two chemicals since 1997; industry, meanwhile, develops two new chemicals every day.

This article was originally posted at http://ehstoday.com/standards/osha/report_obstruction_osha_standards_1007/

Understanding OSHA


Understanding OSHA

OSHA stands for Occupational Safety and Health Administration. The main objective of this Federal organization is to enforce rules and regulations related to safety of workers at worksites. It is an enforcement wing of Department of Labor (DOL) and oversees inspection of worksites to check for hazards, offers advice to the employers how to remove them, educate the workers to follow the right safety procedures to eliminate or reduce the risks, and check the locations or worksites that have not been inspected.

To enforce safety norms, OSHA employs inspectors, technical experts, standard writers and compliance investigators, who are highly trained professionals and experts in their fields. The inspectors have the right to inspect any worksite at random in an appropriate manner and time. They have the right to question an employer or employee to know about the true facts of the work environment of the site.

Hazardous places or worksites are given the inspection priority because of very higher incidence of accidents, illness and the resultant fatalities. The inspector takes a tour of the site and if they find that the working conditions are not as per regulations then the employer can be either warned or fined. For willful violation of law, stricter penalties are imposed.

There are different activities that OSHA undertakes:

  • Provides assistance to the employers to make the worksites safer.
  • Encourages employees to follow the safety rules through various programs.
  • Targets workplaces that have the most numbers of accidents and illness.
  • Takes regulatory actions against defaulters for violations.
  • Creates partnerships with workers and employers to improve onsite safety.

Maintains records of all the workplaces inspected and provides safety information to all workers of facility.The enforcement agency uses its’ vast infrastructure and resources to keep track on the various work sites and punish the offenders through fines and imprisonment. At the same time it educates employers and employees through various programs on how to create a safe work environment and protect precious lives from various hazards.

OSHA compliance helps to save precious human lives.

To know more, visit http://www.empowerbpo.com

Jason Gaya

Health Conferences in Sept. – Oct.


Health Conferences are the best place for knowledge and Networking.

Short Intro To emPower e-Learning.

emPower provides Regulatory Compliance solutions for hospitals and healthcare organizations through Learning Management System (LMS). Learning Management system is an excellent vehicle that lets you deliver, track and manage training/education.

emPower offers courses to stay in compliance with standards set by regulatory bodies such as HIPAA, OSHA, Joint Commission and Red Flags Rule etc. Our parent company Mediscribes, Inc. is a top notch medical transcription provider offering comprehensive medical transcription services and document management system to hospitals and physician practices.           

emPower and Mediscribes would be visible to you at various conferences in the month of September – October, 2009.

GEMMS User Group Conference Indianapolis, Indiana on September 16-18 2009. This conference addresses anyone who uses the GEMMS ONE system – physicians, administrative, clinical, practice management, and IT personnel to learn, network, and share information. At the conference you would find emPower and Mediscribes displaying their various products and solution – comprehensive Healthcare compliance solutions through Learning Management System covering HIPAA, OSHA, HR policies, Red Flags rule training packages, etc. Also, Mediscribes that deals with high end Medical Transcription service would displays its deep insights on web-based electronic medical transcription service for hospitals, clinics, individual and group practices and rehabilitation centers.

Another exciting conference followed in the next week would be MedAxiom conference in Monarch Beach, CA, September 23 – September 25, 2009. MedAxiom is one of the most valuable resources and a comprehensive subscription-based service provider for cardiology practices. MedAxiom conference keeps members informed of changing technologies, trends, strategies and best practices in cardiology-practice administration and service delivery. Cardioscribes is Mediscribes’ extended hand that aces in providing high quality Cardiology Transcription services; it delivers robust document management system that allows Cardiology practices to capitalize on their patient documentation. Cardioscribes ensures consolidated end-to-end transcription solution that lets you around 25 – 35% lower cost than what cardiology practices incurs.

emPower / Mediscribes would also be visiting 81st AHIMA Convention and Exhibit at Gaylord Texon Resort & Convention Center, Grapevine TX in the month of October 3-8, 2009.

AHIMA 2009 convention will feature education and networking opportunities to a wide spectrum of professionals, from entry-level to middle and senior management, and also in areas like information systems.

Cutting-edge technology that provides cost-effective and end to end solution to meet your medical transcription needs ensuring high quality standards. You would be pleased to see product presentation and live demos of all our e-learning solution – healthcare compliance training, HIPAA training, HR policies, Red Flags Rule regulation education, JCAHO and OSHA Training packages.

Last but not least – MGMA 2009 Annual Conference Denver in the month of October 11th – 14th 2009. MGMA’ 2009 Annual conference is the largest professional development and networking conference for medical practice administrators. The Medical Group Management Association (MGMA) 2009 Annual Conference will help you to know what’s going on with HEALTH CARE Reform and how it will impact your business in the near future. In addition to transcription service provided by Cardioscribes and Mediscribes also presents Health care practices with dictation and transcription work-flow systems, software development, EMR interface and voice recognition integration. Besides, this you could also find emPower elearning solutions with broad collection of e-learning, e-reference and blended learning that drive business results. Our online courses cover compliance solutions and Human resource policies effectively covering full range of business needs.

I’m really excited and look forward to meet so many people and companies. 

You could find me at Mediscribes / Cardioscribes / emPower exhibition booth.

Looking forward to see YOU there

J.G.

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